These comments were submitted as public comments to the Board of Directors of the Erie Canal Harbor Development Corporation on September 24, 2014.

Representatives of Citizens for Regional Transit attended the Outer Harbor public meeting at the WNED Studios on September 9th as well as the previous public meetings. We hope that feedback received from community organizations and individuals will be used by the ECHDC to establish a framework for an Outer Harbor that complements our city, takes best advantage of the unique location and character of the Outer Harbor, and reflects the concerns of WNY citizens. However, we are disappointed with the planning process because it restrains and limits public engagement. We also are opposed to some key aspects of the preferred plan.

The fundamental problem with the process is that it does not allow adequate ability for the public to voice concerns and ask questions. Without meaningful public engagement the plan will not reflect public desires for the use of this public land, and it will not benefit from the expertise of organizations knowledgeable in important issues relating to development of the Outer Harbor. For example, relegating public comments at meetings to “yellow stickies” and informal small group discussions does not provide an effective means for the public to raise questions, and does not require the ECHDC and its contractor to respond publicly, on the record. This short circuits the openness of the process and leads to results not fully reflective public views. We want a chance to publicly express our views and to be informed by the views of other groups and citizens. The ECHDC should want this too. We hope that the next public meeting will allow public comments and discussion of issues, and will provide a forum for the ECHDC to respond publicly. Microphones should be available for this purpose.

Also, we are concerned that the preferred plan calls for significant mixed-use development on the Outer Harbor. One ECHDC representative after the meeting said that this could include apartments for 4,000 to 6,000 people. Here are our concerns and questions about this aspect of the plan.

1. Infrastructure costs. What are the costs of the new infrastructure (e.g., roads, sewer, water, electrical)? Will developers pay for these facilities? Who will be responsible for maintaining them in perpetuity? The City of Buffalo? Erie County? New York State? We believe this is just more sprawl that will take more tax dollars to maintain. We should invest in improving our existing infrastructure (e.g., fixing our antiquated sewer system, extending the light rail) rather than building new infrastructure. Investment in new mixed-use development would be better made in the Cobblestone District or First Ward; locations that have existing infrastructure, space for development, and are near the inner and Outer Harbors.

2. Transportation. More development on the Outer Harbor will require more transportation facilities to be developed and maintained. As we stated at the recent ECHDC Board Meeting, we strongly support the planned ferry as a way to get to and from the Outer Harbor. This is affordable and perfect for low-density uses such as a park and hiking trails, perhaps supplemented by a fun people mover like the tram at Niagara Falls and / or bike rentals. The presentation called for extending the light rail to the Outer Harbor. As a transit advocacy organization, we strongly support extending the light rail, but not to the Outer Harbor. We believe there are higher priorities for extending the light rail where ridership will be greater. Every NFTA study over the last 40 years (and there have been many) identifies the airport and Amherst extensions as the highest priority extensions in terms of ridership and need. The light rail can comfortably carry up to 600 people every 10 minutes. What uses and activities on the Outer Harbor are envisioned to require such high-volume transit? We believe a lower volume, less expensive approach (like the ferry) is better. We also believe the light rail should be extended through the DL&W Terminal and along the old DL&W right-of-way (ROW) toward Riverbend and Larkinville. This NFTA-owned ROW could serve new mixed-use developments in the Cobblestone District and First Ward and could eventually be extended to provide the long-dreamed of and badly needed airport extension.

3. Unique resource. The Outer Harbor is one of the few remaining large open spaces on the Great Lakes. Once lost to development, it will be lost forever. The location of this resource next to a major city makes it well suited for recreational uses. Olmsted recommended a waterfront park for Buffalo but it was never built. We agree with those calling for a park on the Outer Harbor. Large portions of the park can be left in a natural state to minimize the cost of maintenance, while providing a sanctuary for wildlife and people looking to escape the sights and sounds of the built environment.

Thank you for considering these inputs. We hope the ECHCDC will provide a public forum soon where these and other issues can be raised and discussed publicly.